A. Sexual harassment occurs when one employee makes continued, unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature, to another employee, against his or her wishes.
Quid pro quo- In legal usage, quid pro quo indicates that an item or a service has been traded in return for something of value, usually when the propriety or equity of the transaction is in question. For example, under the common law, a binding contract must involve consideration: that is, the exchange of something of value for something else of economic value. If the exchange appears excessively one sided, courts in some jurisdictions may question whether a quid pro quo did actually exist and the contract may be void by law.

Hostile environment harassment- employment discrimination consisting of unwelcome verbal or physical conduct (as comments, jokes, or acts) relating to the victim's constitutionally or statutorily protected classification (as race, religion, ethnic origin, or age) that has the effect of substantially interfering with a person's work performance or of creating a hostile work environment.
Pollard was a victim of hostile environment harassment. In the case Gallagher v. C.H. Robinson, even though members of both sexes were exposed to the offensive conduct in the Cleveland office, considering the nature of the patently degrading and anti-female nature of the harassment, it stands to reason that women would suffer, as a result of the exposure, greater disadvantage in the terms and conditions of their employment than men.

B. In Cobb v. Community Action Council (CAC) for Lexington-Fayette, 2008 WL 1087122 (Ky.App). Ms. Cobb was employed by CAC since 1999 as an administrative assistant. In 2002 a Mr. Hinton became her boss. Ms. Cobb alleged that from April 2002 to September 2002, Mr. Hinton made inappropriate and sexual comments to her. He indicated to her that he wanted a sexual relationship. She told him ‘no.’ But in September of 2002, Mr. Hinton exposed himself to her. He did so again in October 2002. From October 2002 through April 2003, Mr. Hinton forced Ms. Cobb to perform oral sex on him six to twelve times. He would threaten her with her job if she told or did anything about it. In early 2003, the staff members all got together and had a secret meeting to discuss Mr. Hinton’s intimidating management style. The labels quid pro quo and hostile work environment are not controlling for purposes of establishing employer liability. The US Supreme Court held that an employer is strictly liable for either form of harassment committed by a supervisor only when it culminates in a “tangible employment action.” If there is no tangible employment action, the employer may still be liable, but it is provided with two affirmative defenses. (Ellerth/Faragher affirmative defense). The defense comprises two elements: 1) that the employer exercised reasonable care to prevent and correct promptly any sexually harassing behavior, and 2) that the plaintiff employee unreasonably failed to take advantage of any preventative or corrective opportunities provided by the employer or to avoid harm otherwise. A tangible employment action is like a firing or failing to promote action.

The question before this appellate court was “whether an employer can be held strictly liable when an employee submits to her supervisor’s sexual demands because she reasonably believes that her benefits or continued employment are conditions upon her acquiescence.” The Second and Ninth Circuits have adopted reasoning which hold that an employee’s submission to a supervisor’s sexual advances in order to retain employment constitutes a tangible employment action and hence subjects the employer to strict liability. But, a subsequent US Supreme Court Case “Suders” may have nullified that rationale. And this court followed “Suders” and held that CAC was entitled to a Ellers/Faragher defense and that based on the facts, since there were factual issues still unresolved, that summary judgment was not proper and the case was sent back to the trial court.
The case presented is more for a quid pro quo case and not the one Ms. Pollard was involved in.

C. Disparate treatment, in the employment context, refers to when a person is treated differently from others. The different treatment is based on one or more of the protected factors and the different treatment is intentional. This is distinguished from the concept of "adverse impact", which may be unintentional and applies to a protected group rather than an individual. Yes, I would have to say that she was disparately treated as a guard film. Being that she was the only girl. they did not treat her fairly.